Professional Documents
Culture Documents
Table 1
QUALITY SYSTEM REGULATION1
Area Addressed Code of Federal Regulations
Management responsibility 21 CFR, Part 820.20, 22, 25
Handling, storage, distribution, and installation controls 21 CFR, Part 820.120, 140, 150, 160
Records including device master record, device history 21 CFR, Part 820.180, 181, 184, 186, 198
record, quality system record, and complaint files controls
Servicing controls 21 CFR, Part 820.200
Use of statistical techniques to establish, control, and verify the 21 CFR, Part 820.250
acceptability of process capability and product characteristics
1. “Quality system regulation,” CFR 21 Part 820, US Food and Drug Administration, http://www.accessdata.fda.gov/
scripts/cdrh/cfdocs/cfCFR/CFRSearch.cfm?CFRPart=820 (accessed 3 Oct 2005).
Division of Small Manufacturers Assistance There are two types of premarket submissions: a
(DMSA) at telephone number 800-638-2041 or premarket notification, or 510(k), and a premarket
301-638-2041; e-mail DMSA@CDRH.fda.gov. approval (PMA) application. The type of submission
required is based on the device classification, as
Labeling defined in 21 CFR, Part 814.21 Unless specifically
exempted, a premarket notification (510[k]) is
The FDA directions for labeling can be found in 21 required for all Class I and Class II devices. A premar-
CFR, Part 801.19 The term labeling includes package ket notification (510[k]) submission must contain
inserts as well as the information printed on the enough information for the FDA to determine whether
actual label of the package. Labeling requirements the particular device is “substantially equivalent” to
include the name and location of the manufacturer another device that has been previously judged to be
(reprocessor) and adequate direction for the device’s safe and effective and has been cleared for market-
intended use. If the manufacturer (reprocessor) ing/reprocessing. The predicate device selected must
knows of uses other than the intended use of the have the same intended use as the device for which
device, FDA requires the manufacturer (reprocessor) the 510(k) is submitted. The predicate device may be
to provide adequate labeling for alternate uses of the the original SUD of the original equipment manufac-
device as are known. In addition, MDUFMA added turer (OEM) provided that the 510(k) compares the
new labeling requirement for reprocessed SUDs unique characteristics of the submitted device to
(Section 502[v] of the Act). Beginning after January those of the predicate device so the FDA can deter-
26, 2004, reprocessed SUDs that are introduced into mine equivalency with respect to safety and effective-
interstate commerce must prominently and conspic- ness. The following information is required for a pre-
uously bear the statement “Reprocessed device for market notification (510[k]) submission:
single use. Reprocessed by [insert the name of the ♦ device trade name, proprietary name, usual
manufacturer that reprocessed the device].”2 For name, or classification name;
additional information about labeling requirements, ♦ entity registration number;
obtain a copy of the FDA guidance document Label- ♦ device classification;
ing Regulatory Requirements for Medical Devices ♦ action taken to determine device perform-
from http://www.fda.gov/cdrh/dsma/470.pdf or con- ance standards;
tact the Division of Small Manufacturers Assistance ♦ proposed labels, labeling, and advertisements
(DSMA) by phone at 800-638-2041 or 301-638- to describe the device, its intended use, and
2041; e-mail DMSA@CDRH.fda.gov. the directions for its use, including photos
and/or engineering drawings if appropriate;
Premarket Approval and ♦ appropriate data to show that the registered
Premarket Notification entity has considered the consequences and
effects any changes or modifications in the
After registering with the FDA and submitting a list device might have on the safety and effective-
of devices to be manufactured (reprocessed) and ness of the device;
distributed for use, the registered entity must meet ♦ 510(k) summary or 510(k) statement as
premarket submission requirements for each listed defined in 21 CFR, Part 807.92, 93;22
device. Certain devices may be exempt from the ♦ financial disclosure statement;9
premarket submission requirement. If exempt, the ♦ statement certifying truth, accuracy, and com-
device need only be listed with the FDA. Additional pleteness of material submitted; and
information about exemptions can be found in 21 ♦ any other information requested by the FDA.
CFR, Part 807.75.20 The FDA has defined a phase-in For specific guidance on preparing 510(k) sub-
period for premarket submissions to accommodate missions, consult Regulatory Requirements for Med-
entities that are presently engaged in reprocessing. ical Devices, available at http://www.fda.gov/cdrh
Following the phase-in period, a premarket submis- /manual/510kprt1.html, or contact the Division of
sion must be submitted for any new device to be Small Manufacturers Assistance. Locate other rele-
manufactured (reprocessed) at least 90 days before vant guidelines at http://www.accessdata.fda.gov
beginning distribution of the device. /scripts/cdrh/cfdocs/cfGGPSearch.CFM.
All Class III devices require a PMA. A PMA appli- correction or removal is initiated by the manufacturer
cation must include valid scientific evidence demon- (reprocessor) to reduce a health risk to the user or to
strating the safety and effectiveness of the original correct a violation of the Food, Drug, and Cosmetic
and/or reprocessed device. Each PMA application Act. For example, if a facility reprocessed an SUD
should evaluate the unique characteristics of the sub- that resulted in a patient’s adverse reaction and the
mitted device. Clinical data (eg, results of clinical tri- hospital chose to remove the remainder of the lot of
als) may be required. Some clinical trials require FDA those reprocessed SUDs from circulation to decrease
approval of an investigational device exemption the possibility of other patients having adverse reac-
(IDE) application for the device(s) to be studied. For tions, that action would be a removal and the facility
additional information, consult the following sources: would be required to report the removal to the FDA.
♦ 21 CFR, Part 814.20;21 Corrections are defined as
♦ 21 CFR, Part 812;22 the repair, modification, adjustment, relabel-
♦ Device Advice: Premarket Approval (PMA), ing, destruction, or inspection of a device with-
available at http://www.fda.gov/cdrh/devadvice out its physical removal from its point of use.23
/pma (accessed 3 Oct 2005); Removal is defined as
♦ Guidance for Institutional Review Boards and the physical removal of a device from its
Clinical Investigators, “Significant risk and point of use to some other location for repair,
nonsignificant risk medical device studies,” modification, adjustment, relabeling, destruc-
available at http://www.fda.gov/oc/ohrt tion, or inspection.23
/irbs/devices.html (accessed 3 Oct 2005); and Distributed devices withdrawn from the market-
♦ Device Advice: Clinical Trials and Investiga- place due to a minor violation of the Food, Drug,
tional Device Exemption (IDE), available at and Cosmetic Act or as a matter of stock rotation
http://www.fda.gov/cdrh/devadvice/ide need not be reported. Stock recoveries need not be
/application.shtml (accessed 3 Oct 2005). reported, nor should devices removed for routine
The FDA also requires a satisfactory inspection of servicing. The term stock recoveries refers to
the manufacturing (reprocessing) facilities before devices that have been prepared for use, but have
approving a PMA application. The application should not left the physical premises and jurisdiction of
include a comprehensive manufacturing (reprocess- the manufacturer (reprocessor)—eg, devices that
ing) section that clearly identifies all manufacturing have not left the reprocessing area. However, each
(reprocessing) controls. Under MDUFMA, some correction and/or removal must be documented
SUDs that previously were exempt from 510(k) sub- regardless of whether it is reported to the FDA.
mission requirements under Sections 510(l) or (m) of When a report must be filed with the FDA, the
the Act are no longer exempt and are required under report must be filed within 10 days of the correc-
Section 510(o)(2) of the Act to submit 510(k) notifica- tion/removal action. The report should include the
tions that include validation data. Validation data also following information:
was required for some reprocessed SUDs that already ♦ registration number of the entity manufactur-
had been cleared under 510(k). Under Section 510(o) ing/reprocessing the device;
of the Act, reprocessors that either did not submit val- ♦ date of the report;
idation data for those reprocessed SUDs within speci- ♦ sequence number of the report from that entity;
fied time frames or received “not substantially equiva- ♦ name, address, and telephone number of the
lent letters” from the FDA can no longer legally reporting entity;
market those reprocessed devices. Finally, under Sec- ♦ name, title, address, and telephone number
tion 515(c)(2) of the Act, reprocessors of Class III of individual responsible for the correction/
SUDs are required to submit premarket reports removal action;
instead of premarket approval applications.2 ♦ brand name, classification name, and com-
mon name of the device and its intended use;
Medical Device ♦ marketing status of the device;
♦ model, catalog, and code number of the
Corrections and Removals device and the manufacturer’s (reprocessor’s)
Device correction and/or removal from the point of lot, serial, or other identification number for
use must be promptly reported to the FDA when the the device;
♦ description of event leading to correction/ able assurance of device safety and effectiveness but
removal action; for which there is sufficient information to establish
♦ any injuries resulting from device use; special controls (eg, performance standards, guide-
♦ total number of devices manufactured lines, patient registries, postmarket surveillance) to
(reprocessed) subject to the correction/ provide that assurance.23
removal action; Class III medical device: A medical device for
♦ date of manufacture/distribution/reprocessing which neither general controls nor special controls
and expected shelf life of the device; provide reasonable assurance of device safety and
♦ name, address, telephone number of all to effectiveness and the device is life-supporting or
whom the device has been distributed and the life sustaining or its use “is of substantial impor-
number of devices distributed to each; and tance in preventing impairment of human health”
♦ copies of all communication regarding the cor- or “presents a potential risk of illness or injury.”23
rection/removal action and the names and Opened-but-unused device: A device whose
address of all recipients of the communication. sterility is compromised before being introduced
For additional information about correction and onto the sterile field and which is not contami-
removal requirements, consult 21 CFR, Part 806. nated with blood and/or other potentially infec-
tious materials (OPIM) external to the sterile field.24
Medical Device Tracking Reprocessing: Includes all operations to render a
contaminated reusable or single-use device patient
Medical device tracking is intended to ensure that ready. Single-use devices to be reprocessed may be
manufacturers (reprocessors) of certain devices can either used or unused. Reprocessing steps include
locate those devices should corrective action and/or cleaning, decontamination, and sterilization/
notification about such devices become necessary. disinfection.9
Original equipment manufacturers are subject to the Resterilization: The repeated application of a
medical device tracking regulation only when the process intended to remove or destroy all viable forms
FDA issues a tracking order for a device manufactured of microbial life, including bacterial spores.9 Because
by the OEM. Reprocessors are subject to the medical sterility is not an absolute, the accepted sterility assur-
device tracking regulation only when the FDA issues ance level (SAL) is usually defined as 10–6.
an order for the specific device(s) being reprocessed. Reuse: The repeated or multiple uses of any
For additional information on device tracking, includ- medical device whether marketed as reusable or
ing the types of devices currently subject to tracking single-use. Repeated/multiple use may be on the
orders, consult Guidance on Medical Device Track- same patient or on different patients with applica-
ing, available at http://www.fda.gov/cerh/modact/ ble reprocessing of the device between uses.25
tracking/pdf or from the Center for Devices and Radi- Single-use device (SUD): A device intended by the
ologic Health (CDRH) at 301-827-0111. Request manufacturer to be used on one patient during one
document number 169. procedure. The device is not intended for reprocess-
ing and/or use on another patient or on the same
Definitions patient at another time. Device labeling may or may
not identify the device as single-use or disposable, but
Class I medical device: A medical device for manufacturer instructions for reprocessing are absent.9
which general controls provide reasonable assur- Third-party reprocessor: A business establish-
ance of the safety and effectiveness of the device ment, separate from the user facility and the device
or, if there is insufficient evidence to reasonably manufacturer, one of whose primary businesses is
ensure safety and effectiveness, the device is not to reprocess single-use/disposable medical devices.
life-supporting or life-sustaining, its use is not sub-
stantially important in preventing impairment of NOTES
human health, and/or its use “does not present a 1. “Reuse of single-use devices,” AORN Journal 73
(May 2001) 957-966.
potential unreasonable risk of illness or injury.”23 2. “Medical Device User Fee and Modernization Act
Class II medical device: A medical device for (MDUFMA) of 2002,” PL 107-250, 107th Congress,
which general controls alone do not provide reason- http://www.fda.gov/cdrh/mdufma (accessed 3 Oct 2005).
3. “Guidance for industry and for FDA staff: Enforce- tration, http://www.accessdata.fda.gov/scripts/cdrh
ment priorities for single-use devices reprocessed by third /cfdocs/cfcfr/CFRSearch.cfm?CFRPart=803 (accessed 23
parties and hospitals,” (Aug 14, 2000) US Food and Drug Aug 2005).
Administration, http://www.fda.gov/cdrh/reuse/1168.html 16. “User facility reporting requirements,” CFR 21,
(accessed 3 Oct 2005). Part 803, Subpart C, US Food and Drug Administration,
4. “Medical devices; reprocessed single-use devices; http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr
termination of exemptions from premarket notification; /CFRSearch.cfm?CFRPart=803 (accessed 23 Aug 2005).
requirement for submission of validation data,” US Food 17. US Department of Health and Human Services,
and Drug Administration, http://www.fda.gov/OHRMS “Medical device reporting: Manufacturer reporting,
/DOCKETS/98fr/03-16109.html (accessed 3 Oct 2005). importer reporting, user facility reporting, distributor
5. “AORN explications for perioperative nursing,” in reporting,” Federal Register 65 (Jan 26, 2000) 4112-4121.
Standards, Recommended Practices, and Guidelines 18. “Establishment regulation and device listing for
(Denver: AORN, Inc, 2005) 86-115. manufacturers and initial importers of devices,” CFR 21,
6. Joint Commission on Accreditation of Healthcare Part 807, US Food and Drug Administration, http://www
Organizations, “Standard LD.3.50: Services provided by .accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFR
consultation, contractual agreements, or other agree- Search.cfm?CFRPart=807 (accessed 23 Aug 2005).
ments are provided safely and effectively,” in Compre- 19. “Labeling,” CFR 21, Part 801, US Food and Drug
hensive Accreditation Manual for Hospitals (Oakbrook Administration, http://www.accessdata.fda.gov/scripts
Terrace, Ill: Joint Commission on Accreditation of /cdrh/cfdocs/cfcfr/CFRSearch.cfm?CFRPart=801
Healthcare Organizations, 2005) LD 13. (accessed 23 Aug 2005).
7. “Letter re: Reusable medical devices rented or 20. “Exemption from premarket notification,” CFR 21,
leased from third parties,” US Food and Drug Administra- Part 807.65, US Food and Drug Administration, http://www
tion, http://www.fda.gov/cdrh/comp/rentleasethird.html .accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm
(accessed 23 Aug 2005). ?fr=807.65 (accessed 23 Aug 2005).
8. “Quality system regulation, Definitions,” CFR 21, 21. “Premarket approval of medical devices,” CFR 21,
Part 820.3, US Food and Drug Administration, http:// Part 814, US Food and Drug Administration, http://www
www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfCFR .accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm
/CFRSearch.cfm?fr=820.3 (accessed 3 Oct 2005). ?CFRPart=814 (accessed 23 Aug 2005).
9. “Letter to American College of Healthcare Execu- 22. “Investigational device exemptions,” CFR 21, Part
tives: Reuse of single-use or disposable medical 812, US Food and Drug Administration, http://www.access
devices,” US Food and Drug Administration, http:// data.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?CFR
www.fda.gov/cdrh/comp/policymayaply.html (accessed Part=812 (accessed 3 Oct 2005).
3 Oct 2005). 23. “Medical devices: Reports of corrections and
10. Center for Devices and Radiological Health, US removals, definitions,” CFR 21, Part 806.2, US Food and
Food and Drug Administration, US Department of Health Drug Administration, http://www.accessdata.fda.gov/scripts
and Human Services, Enforcement Priorities for Single- /cdrh/cfdocs/cfcfr/CFRSearch.cfm (accessed 3 Oct 2005).
Use Devices Reprocessed by Third Parties and Hospitals 24. “Guidance for industry and for FDA staff: Enforce-
(Washington, DC: US Government Printing Office, Aug ment priorities for single-use devices reprocessed by third
14, 2000). parties and hospitals,” US Food and Drug Administration,
11. “Quality system regulation,” CFR 21, Part 820, US http://www.fda.gov/cdrh/reuse/1168.html#_Toc492780057
Food and Drug Administration, http://www.accessdata (accessed 2 Feb 2006).
.fda.gov/scripts/cdrh/cfdocs/cfCFR/CFRSearch.cfm?CFR 25. Center for Devices and Radiological Health, US
Part=820 (accessed 3 Oct 2005). Food and Drug Administration, US Department of Health
12. “Safe Medical Devices Act of 1990,” Public Law and Human Services, “FDA’s proposed strategy on reuse
101-629, http://thomas.loc.gov/cgi-bin/query/C?c101:./temp of single-use devices, docket no 99N-4491,” Federal
/~c101exIXhd (accessed 23 Aug 2005). Register 64 (Nov 3, 1999) 59782-59783.
13. “Medical device reporting: General provisions,”
CFR 21, Part 803.1, US Food and Drug Administration, RESOURCES
http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr Medical Device Quality Systems Manual: A Small Entity
/CFRSearch.cfm?fr=803.1 (accessed 3 Oct 2005). Compliance Guidance, US Food and Drug Adminis-
14. “Manufacturer reporting requirements,” CFR 21, tration, http://www.fda.gov/CDRH/DSMA/GMP
Part 803, Subpart E, US Food and Drug Administration, MAN.HTML (accessed 3 Oct 2005).
http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr
/CFRSearch.cfm?CFRPart=803 (accessed 23 Aug 2005).
15. “Medical device reporting: General provisions,” Scheduled for publication in the AORN Journal in
CFR 21, Part 803, Subpart A, US Food and Drug Adminis- 2006.